Posts

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Evaluating Investment Proposals With Enhanced Due Diligence

Understanding the impact that new business decisions can have on a credit union’s risk profile is central to effective asset/liability management, and is even addressed in NCUA’s recently issued Interest Rate Risk Questionnaire.  This is especially appropriate when evaluating proposals from investment brokers seeking to “rebalance” or “strategically realign” a credit union’s investment portfolio.
Many of our clients have received proposals from their brokers to sell investments they currently own for a gain and replace those sold with comparable investments (albeit at lower yields).  Accompanying these proposals are broker-provided due diligence information packets that show the current portfolio price risk compared to the proposed portfolio price risk in a +300, WAM for the current portfolio and proposed portfolio in a +300 and other industry-standard measures of risk.  While many of these proposals can offer an acceptable balance between risk and return given an individual credit union’s unique circumstances and appetite for risk, some proposals can be downright disastrous, resulting in significant interest rate risk with even the slightest change in interest rate environment.
To appropriately safeguard against making a decision that is inconsistent with a credit union’s normal practice, or board-directed appetite for risk, a certain measure of independent due diligence is highly recommended.  For example, ask your broker to provide the same reports with a shock higher than the traditional +300 (+500 is recommended—before rates plummeted to today’s low levels, short-term rates were roughly 5% for a sustained period).  You should also ask your broker to twist the yield curve (non-parallel shock).
Nearly every broker-provided proposal generates an increase in net worth dollars, and a corresponding increase in net worth ratio.  The key in realizing the potential risks of executing on a proposal is understanding how the amount of net worth not at risk changes, and in what interest rate environments this becomes a negative change.  Understanding margin changes today, as well as changes in price risk in a +300, can be valuable tools.  However, testing the potential impact on net worth is critical when evaluating the risk in a business decision, and this level of testing is typically not included with any standard broker-provided due diligence.
Remember, in NCUA’s Final Rule on Interest Rate Risk Management, NCUA states “net worth is the reserve of funds available to absorb the risks of a credit union, and it is therefore the best measure against which to gauge the credit union’s risk exposure.”  Ensuring that decision-makers have the appropriate information to drive effective decision-making is an integral part of ensuring that an interest rate risk program is effective, and is incorporated in the risk management process of high-performing credit unions.
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Callables and Low Rate Environments

Trying to get any kind of yield on investments is tough when rates are this low. Some credit unions are reaching for yield by purchasing longer-term callables with the justification that “we don’t have to worry much about the risk because they are going to get called.” But consider this, if rates move up even a little bit, most callable bonds will not get called, and the credit union could be stuck with material losses. The example table below demonstrates this potential risk.

The example assumes that a $1M 1/5 callable (callable in 1 year, final maturity in 5 years) is purchased today at 80bp. It shows that, compared to Overnights earning 25bp, this investment would yield an additional $6K in revenue over the course of 1 year, at which point it would be called. However, when you layer on industry-average cost of funds, operating expense and fee income, it reveals that from an ROA perspective this investment loses $19K in year 1. If rates go up at all, the bond will stick around for the full 5 years, and in a +300bp rate environment the bond would lose about $147K over its lifetime when the credit union cost of funds, operating expense and fee income are factored in. If rates returned to levels seen in 2007 (5%), this bond would lose $190K over its lifetime.

Note that for simplicity sake it is assumed that rates move immediately.

Some credit unions can afford to take this risk, some cannot. In any case, the decision to buy longer-term callables should NOT be based solely on the expectation that they will be called; the consequences of being wrong could have a very negative impact on a credit union’s risk profile and future earnings.

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Strategic Plans And Quantifying Risk

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In the recently issued Interest Rate Risk Questionnaire, the NCUA devoted an entire section to evaluating if decision-making is informed by interest rate risk measurement systems.  The guidance specifically references interest rate risk “what-if” testing in conjunction with strategic plans and operational decisions—and that “what-if” analysis outcomes should be documented within the strategic plan to either support or reject a decision.

The NCUA further states, “Whenever material changes in assets or liabilities are proposed, NCUA expects management to be proactive and perform what-if analysis before a new strategy is implemented.”  Understanding the potential impact that a strategic plan may have on the credit union’s risk exposures is key to effective asset/liability management.

In order to link strategic planning and desired long-term financial performance, decision-makers should ask themselves the following questions:

  1. How does this plan align with our long-term goals for financial performance?
  2. Is there a possibility that we will sacrifice financial performance in the short- or medium-term to fulfill long-term strategic and/or financial objectives?
  3. If everything goes according to our strategic plan, what will be the impact to the interest rate risk and credit risk exposure of the credit union?  Are there any other risks that may be present in the strategy that we don’t have today?  Specifically, how will those risks impact earnings and net worth levels?
  4. If external forces cause a deviation from our strategic plan, what contingencies are in place or what options do we have to get back on track?

A comprehensive strategic planning process incorporates the evaluation of interest rate risk.  Modeling the impact of strategic decisions beyond the traditional 1-year simulation is a must.

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Policy Limits And The Proposed Regulation For IRR

The following is an excerpt from our response to NCUA’s proposed regulation on IRR.  While the excerpt focuses on a potential issue with the proposed regulation, it also highlights a concern we have with the way certain policy limits are written that don’t look at the actual risk of an institution.

Appropriate Policy Limits

Another concern is the evaluation of appropriate policy limits to ensure “compliance” with the regulation.  The proposed regulation states:

  • Set risk limits for IRR exposures based on selected measures (e.g. limits for changes [emphasis ours] in repricing or duration gaps, income simulation, asset valuation, or net economic value); (Federal Register, Page 16575).

While NCUA has stated in the proposed regulation that these are examples of the types of limits to set and how to set them, the concern is that these examples will become the rule.

Our question is:  Why the focus on percent change versus focusing on the actual risk?

If a line in the sand is never drawn, then as long as a credit union continues to be within the percent change they identified, it would be acceptable for their risk profile to continue to deteriorate.  Also, these types of limits don’t address if the credit union has an adequate net worth ratio.

Consider the following example if the guidance NCUA provides to examiners regarding this proposed regulation is similar to that in the below excerpt from the IRR Questionnaire (click on image to see Table A):


If a credit union has a 1.00% ROA, to maintain a “moderate” level of risk to earnings, the ROA can’t fall below 0.25% (maximum 75% decline) in a 300bp change.  Whereas, a credit union with a 0.40% ROA can have their earnings drop to 0.10%.   What if, at the time of the next simulation, the credit union with a 1.00% ROA is at 1.25%?  Then their ROA can’t fall below 0.31%.  If the credit union that was earning 0.40% now earns 0.30%, then their earnings can’t fall below 0.08%.

In essence, using the percent change methodology, if an institution’s earnings increase in the future, the bar is raised.  Conversely, if earnings drop in the future, the bar is lowered.  Is this really a good measure of safety and soundness?

Additionally, a percent decline approach applied to earnings would never allow a credit union with positive earnings to make the business decision to allow for negative earnings.  There are several cases where external forces or strategic plans make negative earnings in the short term a reality in order to balance the long-term viability of the organization.

Using these guidelines would put any credit union with negative earnings out of policy.  Does that mean that every credit union losing money would automatically be “out of compliance”?  Note that, in 2010, approximately 40% of all credit unions had negative earnings after factoring additional NCUSIF expense.  The potential ramification of this path could be detrimental to the industry.

To see our full response, please click here.

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Proposed Interest Rate Risk Regulation

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Newly proposed regulations would require federally insured credit unions to not only have an effective interest rate risk management program, but also a written policy addressing interest rate risk management.  The NCUA has taken this step due to concerns about the level of interest rate risk being taken by many institutions, as material concentrations in long-term, fixed-rate assets continue to be booked in this historically low rate environment—funded largely by short-term deposits.

Most often, managements and boards establish limits at the category or portfolio level, not at the enterprise/aggregate level.  It is not uncommon to see a credit union within their individual category or portfolio levels, yet have a relatively high level of risk at the enterprise level.  In other words, the combination of the individual risks can create an undesirable, aggregate risk profile.  Therefore, agreeing on and managing to aggregate risk levels is a key component of an effective risk management process.  However, establishing aggregate risk limits that make sense from a business perspective, as well as from a safety and soundness perspective, requires in-depth discussions and critical thinking.

These limits can also be a critical driver of financial success both today and as rates change.  So take your time and think it through.

While we believe it is prudent for decision makers to establish enterprise/aggregate risk limits, it is not intended as an endorsement for the proposed regulation.  We will write more on the proposed regulation soon.